News & Analysis as of

Commodity Pool Operator › Exemptions

Commodity Pool Operators are individuals who manage and secure capital for commodity pools. Most commodity pool operators are required to register as CPOs, unless they qualify for a registration exemption under... more +
Commodity Pool Operators are individuals who manage and secure capital for commodity pools. Most commodity pool operators are required to register as CPOs, unless they qualify for a registration exemption under the Commodity Futures Trading Commission regulations.  less -
Akin Gump Strauss Hauer & Feld LLP

CFTC Proposes to Codify Existing Staff-Issued Relief from Registration and Other Compliance Requirements for CPOs and CTAs

Akin Gump Strauss Hauer & Feld LLP on

• CPOs and CTAs of offshore commodity pools, family offices and business development companies would be exempt from registering with the CFTC. • Certain registered CPOs and CTAs would not be required to file Form CPO-PQR...more

Eversheds Sutherland (US) LLP

Affirmations of CPO and CTA registration exemptions are due by March 1, 2018

Eversheds Sutherland (US) LLP on

Persons claiming exemptions from registration as a commodity pool operator (CPO) or a commodity trading advisor (CTA) must affirm their exemptions by March 1, 2018. Pursuant to Commodity Futures Trading Commission (CFTC)...more

Morgan Lewis

Deadline Approaches for Annual CPO/CTA Exemption Filings

Morgan Lewis on

Firms must affirm their exemption or exclusion from CPO or CTA registration on the National Futures Association’s Exemption Filing System by February 29....more

Dechert LLP

CFTC Issues Exemptive Relief Related to JOBS Act Amendments to Regulation D

Dechert LLP on

The Division of Swap Dealer and Intermediary Oversight (Division) of the U.S. Commodity Futures Trading Commission (CFTC) on September 9, 2014 issued a letter granting exemptive relief from provisions in CFTC Regulations...more

Akin Gump Strauss Hauer & Feld LLP

CFTC Publishes Long-Awaited JOBS Act Relief

Akin Gump Strauss Hauer & Feld LLP on

The staff of the Commodity Futures Trading Commission (CFTC) published a no-action letter on September 9, 2014 (available here) that permits certain commodity pool operators (CPOs) to conduct general solicitation in private...more

Goodwin

NFA Provides Further Guidance on Bylaw 1101 Obligations of Members Who Do Business with CPOs/CTAs Relying on an Exemption or...

Goodwin on

The National Futures Association (the “NFA”) issued Notice I-14-06 providing guidance to its members regarding their Bylaw 1101 obligation to determine the CFTC registration and NFA membership status of persons with whom they...more

Katten Muchin Rosenman LLP

NFA Issues Notice to Members Regarding Member Obligations Under NFA Bylaw 1101 and Compliance Rule 2-36(d)

Katten Muchin Rosenman LLP on

Under Commodity Futures Trading Commission regulations, any person claiming an exemption or exclusion from commodity pool operator (CPO) or commodity trading advisor (CTA) registration pursuant to CFTC Regulations 4.5,...more

Eversheds Sutherland (US) LLP

CPO and CTA Annual Affirmation of Exemptions Due in March

Eversheds Sutherland (US) LLP on

Pursuant to Commodity Futures Trading Commission (CFTC) regulations, persons claiming an exemption or exclusion from registration as a commodity pool operator (CPO) or a commodity trading advisor (CTA), under CFTC Regulations...more

Goodwin

NFA Issues Guidance on Annual Affirmation Requirement for Entities Operating Under An Exemption or Exclusion from CPO or CTA...

Goodwin on

The National Futures Association (the “NFA”) has issued guidance reminding market participants of CFTC regulations that require any person claiming an exemption or exclusion under CFTC Regulation 4.5, 4.13(a)(1), 4.13 (a)(2),...more

Broker-Dealer Compliance + Regulation

Year-End CFTC Reporting Requirements for Fund Advisers

Broker-Dealer Compliance + Regulation on

The National Futures Association (NFA) reminded fund advisers claiming an exemption from registering as a commodity pool operator (CPO) that they must confirm by March 3, 2014 that will continue to rely on the exemption....more

Katten Muchin Rosenman LLP

NFA Issues Guidance on Affirmation Process for CPO and CTA Exemptions and Exclusions

Katten Muchin Rosenman LLP on

The National Futures Association (NFA) issued guidance on the annual affirmation requirement for persons operating under an exemption or exclusion from commodity pool operator (CPO) or commodity trading advisor (CTA)...more

Miller & Martin PLLC

Family Office Relief from CPO Registration

Miller & Martin PLLC on

As noted in an earlier Client bulletin, the Division of Swap Dealer and Intermediary Oversight (“Division”) of the Commodity Futures Trading Commission (“CFTC”) issued a no-action letter dated November 29, 2012 enabling...more

K&L Gates LLP

CFTC Staff Responds to FAQs Regarding Rescission/Modification of CPO/CTA Registration Exemptions

K&L Gates LLP on

The Division of Swap Dealer and Intermediary Oversight (“DSIO”) of the Commodity Futures Trading Commission (“CFTC”) issued responses on August 14, 2012 to frequently asked questions (“FAQs”) submitted by several trade...more

Katten Muchin Rosenman LLP

CFTC Issues Guidance on Compliance Obligations for CPOs and CTAs

Katten Muchin Rosenman LLP on

On August 14, the Commodity Futures Trading Commission issued a set of responses to frequently asked questions (FAQs) related to the compliance obligations of commodity pool operators (CPOs) and commodity trading advisors....more

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